HoneyLedger Privacy Policy

I. INTRODUCTION

We value our privacy. We like to know what information about us is being collected, how that information is being used, and whether that information is being disclosed to others. Because we realize many of our Users feel the same way, we’ve designed the Website and Service in a way that preserves as much of your privacy as possible. (All capitalized terms not defined in this Privacy Policy are defined in our Terms.)

Generally speaking, we collect, use and disclose information about you only as necessary to provide the best possible user experience. We don’t permit third parties to track you. We don’t license your information to marketing or business "partners." In fact, we don’t disclose your information to anyone, other than as necessary to provide the Website and Service. We preserve information about your use of the Website and Service only as necessary to one of our own legitimate business purposes. And we never attempt to combine usage or other non-personally identifying information with personally identifying information, whether to profile your browsing habits or otherwise.

This Privacy Policy summarizes and provides specific details about the information we collect, use and disclose. The Website and Service are offered subject to your acceptance of this Privacy Policy and our Terms. By using the Website or Service, you represent that you understand and agree to be bound by this Privacy Policy and our Terms. If you do not agree to this Privacy Policy or to our Terms, you may not and should not use the Website or Service.

We may update this Privacy Policy from time to time. We will notify you of any updates by posting a notice on the Website or on your Account dashboard, or by email sent to your most recently provided email address. By continuing to use the Website or Service after receiving notice of an update, you agree to be bound by the updated Privacy Policy. Our use and disclosure of particular information will be governed by the Privacy Policy in effect at the time we gathered that information.

II. INFORMATION WE COLLECT

The information we collect about you falls into two general categories: personally identifying information ("PII") and non-personally identifying information ("NPII"). PII is information that, alone or in combination with other PII, is sufficient to personally identify or contact you (e.g., your name, email or physical address, phone number, etc.). NPII is information that, unless combined with PII, cannot be used to identify or contact you (e.g., IP address, domain server, referring page, click stream data, etc.). You are not required to provide PII in order to use the Website, although your refusal to do so may prevent you from using the Service.

Account Registration Data

As part of the Account registration process, we may ask you to provide a then-current email address, as well as a username, password and perhaps other PII. In addition to or in lieu of that information, Users who register through a content platform may be required to link their Account to their account with that platform. Content Creators may also be asked to provide a full personal or business name, address, tax identification number, and other PII relating to their receipt of voluntary payments. (We refer to information gathered during the Account registration process as "Account Registration Data.")

Log Data

The servers hosting the Website and Service, like most servers, gather NPII of the sort that browsers routinely make available, such as your IP address, domain server, browser type, operating system, date/time, referring and exit pages, and "click stream" data relating to your navigation of the Website and your use of the Service (collectively, "Log Data").

Transaction Data

We will collect NPII about your payment activity, to include the dates/times and amounts of the payments you send and receive, and the User to whom you directed, or from whom you received, each payment (collectively, "Transaction Data"). You may view your Transaction Data through your Account dashboard. All credit card transactions are processed by third-party credit card payment processors. We do not therefore collect or receive credit card-related PII.

User Generated Content

The Website and Service may enable each Content Creator to create a public profile (a "Profile") displaying identifying information, graphics, descriptive text and messages from those who have sent them payments. The Website and Service may also permit Fans to accompany each payment with a message that may appear on the Content Creator’s Profile, as well as on one or more other profiles maintained by the Content Creator on third-party websites. We save Content Creators’ public profiles, Fans’ messages, and other content uploaded and published by Users (collectively, "User Generated Content"), as well as Log Data and other NPII relating to User Generated Content.

Customer Service Data

We collect and save communications (including emails) and other PII and NPII received or created in the course of responding to customer service inquiries. You can reach our customer service department at [email protected]

III. INFORMATION WE USE

As a general matter, we use the PII and NPII we collect about you to only as necessary to provide and improve the Website and Service.

Account Registration Data and Other PII

We use Account Registration Data and the other PII for three primary purposes. The first is to verify your identity, for which purpose we may also use Cookies or similar technologies (see below). The second purpose is to communicate with you, such as in the case of an update to the Terms or Privacy Policy, a security alert, an important User announcement, or a customer service issue. The third purpose for which we use Account Registration Data and other PII is to facilitate the reporting of payments to the extent required by law. Otherwise, we do not use Account Registration Data or other PII.

If you wish to opt out of receiving User announcements or other non-essential communications, you may do so using your Account dashboard. You cannot opt out of receiving updates, security alerts and other essential communications.

Log Data, Transaction Data, Customer Service Data and Other NPII

We use Log Data, Transaction Data, Customer Service Data and other NPII to better understand how you and others are using the Website and Service, and to help us detect security threats and potential fraud. As part of our effort to better understand Website and Service usage, we employ Google Analytics, a service that helps us analyze Log Data and Transaction Data. By better understanding how the Website and Service are used, we are able to refine and expand popular features, increase technical capacity in advance of bottlenecks, and generally improve the Website and Service’s usability, stability and security. We do not attempt to match Log Data, Transaction Data, Customer Service Data and other NPII with PII, or to otherwise profile you based on your use of the Website and Service.

Transaction Data and User Generated Content

We use Transaction Data and User Generated Content to perform certain activities as specifically requested by you or other Users. Those activities include facilitating payment transactions, creating and publishing Content Creator Profiles, and transmitting and displaying Fan messages. We also use Transaction Data and User Generated Content to enable certain functions of your Account dashboard, including your payment transaction and message histories.

Customer Service Data

We use Customer Service Data in conjunction with PII and sometimes NPII to investigate, understand, communicate about and resolve customer service issues.

IV. INFORMATION WE DISCLOSE

Unless we receive your prior consent, we will not disclose information about you except as necessary to a legitimate business purpose or as required by law.

Legitimate Business Purposes

We use third-party vendors to provide various services, including data storage and processing, fraud detection, and Log Data and Transaction Data analysis. We provide those vendors with your PII and NPII, though only as absolutely necessary for them to perform those services. We also require our vendors to contractually agree to treat your information in accordance with the Privacy Policy in effect at the time we collected that information. All the vendors to whom we provide data are located in the United States.

As further explained below, your PII and NPII may be assigned or transferred to a third-party in connection with an acquisition of our assets or, much less likely, our going out of business. We reserve the right to make additional disclosures of PII and NPII as reasonably necessary, in our sole discretion, to protect our business interests and property rights, to enforce agreements such as our Terms and this Privacy Policy, and or to protect personal or public safety.

Reporting Usage and Trends

We will disclose Log Data, Transaction Data and Customer Service Data in non-personally identifying, aggregate form, such as to consultants hired to help improve the Website or Service, or in a report summarizing Users’ content preferences.

User Generated Content

As directed by you, we will transmit, publish or display Profiles, Fan messages, testimonials and other User Generated Content that you provide to us in the course of using the Website or Service. You should exercise caution in creating User Generated Content, as we are not able to control others’ dissemination or use of User Generated Content once it has been made public.

As Required by Law

We will disclose your PII and NPII if we believe, in our sole discretion, that such disclosure is required by law, including by any subpoena, court order or other valid legal process.

V. COOKIES

We use "Cookies," "Web Beacons" and analogous technologies to enable and improve certain functions of the Website and Service. A "Cookie" is a string of data stored by a website on a user’s computer and then provided to the website by the user’s browser on the user’s subsequent visits to the Website. Some cookies remain on a user’s computer until they are deleted, while others last only as long as the user’s then-current visit to the website. A "Web Beacon" is a small piece of software embedded in a web page that helps the website administrator understand how a user interacts with that web page.

We use Cookies and Web Beacons to identify you as a previous user of the Website or Service, and to save certain of your Website preferences, including as indicated by your browser during previous visits. We also use Cookies and Web Beacons for "session management" purposes, meaning to help the Website and Service remember where you are, where you’ve been, and what you’re in the process of doing. Additionally, we use Cookies and Web Beacons to monitor the usage of the Website and Service, to understand how our Users get to us, and to gather other statistical data that we use for purposes of improving your and others’ user experiences.

Most browsers are by default set to accept Cookies and to execute Web Beacons. Most browsers can be set to reject, disable and delete Cookies and Web Beacons, and to inform you when a website is trying to place a Cookie or Web Beacon on your computer. We encourage you to accept or reject our Cookies and Web Beacons as you prefer. Please note, however, that if you reject, disable or delete our Cookies or Web Beacons, certain aspects of the Website and Service may not function properly.

VI. WE DON’T TRACK

Other than for purposes of analyzing Log Data, Transaction Data and Customer Service Data in non-personally identifying, aggregate form, we do not permit third parties to collect information about you or your use of the Website or Service.

VII. THIRD-PARTY WEBSITES

The Website may contain links to third-party websites. We do not have control over those third-party websites, each of which may have its own unique privacy policy and practices. Before using a third-party website, you should familiarize yourself with its privacy policy and practices.

VIII. PROTECTION OF INFORMATION

We follow or exceed generally accepted industry standards for the protection of personal information. For example, we use secure socket layer (SSL) technology to encrypt transmissions of confidential information such as login credentials. We also employ, and require our data processing vendors to employ, physical, administrative and technological safeguards including robust firewalls. Remember, however, that no method of data transmission or storage is fully secure or error free. We cannot therefore guarantee the absolute security of your personal information, and encourage you to use discretion in deciding what information you provide to us.

IX. CORRECTIONS, DELETIONS AND ACCOUNT TERMINATIONS

You can review your Account Registration Data, Transaction Data and User Generated Content at any time using your Account dashboard. You can also use your Account dashboard to correct, update or delete your Account Registration Data. Please note that deletion of your Account Registration Data could result in the termination of your Account. In the event your Account is terminated, we will remove your Profile from public view.

We will retain Account Registration Data, Log Data, Transaction Data, User Generated Content and Customer Service Data as necessary to, in our sole discretion and without limitation, comply with legal requirements, maintain an accurate accounting of payment transactions conducted through or facilitated by the Website or Service, investigate suspected wrongdoing, and enforce agreements including our Terms of Service. By its nature, Log Data cannot be reviewed or deleted, although it may be destroyed in the ordinary course of our business.

X. APPLICABLE USERS OUTSIDE THE U.S.

HoneyLedger may share data internally within our company and your personal information may be processed on a server located in the United States. You consent to having your personal information transferred and processed in the United States.

XI. CHILDREN

HoneyLedger understands and is committed to protecting children’s privacy online. Our Website and Services are not designed for and do not intentionally target or solicit anyone under thirteen (13) years of age. If we learn or have reason to suspect one of our Users is under the age of 13, we will promptly delete any PII in that User’s Account.

XII. YOUR CALIFORNIA PRIVACY RIGHTS

SHINE THE LIGHT

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our Users who are California residents to request and obtain from HoneyLedger once a year, free of charge, information about the personally identifiable information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:

Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response. Also note that under California law, businesses are only required to respond to a shopper’s request once during any calendar year.

ERASER LAW NOTICE TO MINOR USERS

Users who are under 18 years of age and live in California ("Minor Users"), under California SB 568: "Privacy Rights for California Minors in the Digital World", have the right to request HoneyLedger to remove content that such Minor Users post on the Website ("Minor Posted Content"). To request that your Minor Posted Content be removed, please send an email to [email protected] attesting to the fact that you are a Minor User and include your full name, telephone number, email address, current California mailing address, a description of the content you wish to remove and if possible a URL where the content is posted. Please include "California Privacy Rights" in the subject line of your email. Upon receipt of a request, HoneyLedger will use commercially reasonable efforts to remove Minor Posted Content from the Website. Any such request to remove Minor Posted Content does not ensure complete or comprehensive removal of the Minor Posted Content.

XIII. TRANSFER OR ASSIGNMENT

In the event we are acquired by another company or, much less likely, go out of business, your information would be an asset subject to transfer. Of course, any acquirer of your information would be obligated to treat it in accordance with the version of this Privacy Policy in effect when that information was collected. You understand and acknowledge that a transfer of your personal information may occur, subject to your rights under this Privacy Policy.

XIV. UPDATE LOG

March 2, 2015 Original Privacy Policy published and effective.

December 2, 2015 Updates to Users outside the U.S. and California Privacy Rights.